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•                                •  for goods; or goods ready for sale, and reselling such
          & Service           goods were required to be        component parts, materials or goods
          Centre              imported and stored in the    •  Service Centre: providing services to a Foreign
          Business            UAE and resold to outside        Connected Person
                              UAE
                           •  Service Centre: Services
                              needed to be provided to
                              Foreign Connected Persons

                              business outside the UAE
          High Risk IP
          licensee            (2) had to be met for a          a. did not create the intellectual property asset
                              Licensee to be a high risk IP    b. acquired the intellectual property asset from either:
                              licensee                         - a Connected Person, or
                                                               -
                                                               development by another person situated in a foreign

                                                               c. licenses or has sold the intellectual property asset to
                                                               a
                                                               income from a Foreign Connected Person in respect of
                                                                                   of the intellectual property asset
                                                                         : as below, no longer in the

                                                               the Licensee does not carry out research and
                                                               development, or
                                                               as part of its State Core Income-
          Exchange of   Was considered only if the
                        Licensee fails to meet the
                        Economic Substance Test or
                        considered as a “High Risk IP          discussed above under exempted licensee and branches
                        Business”                              de-coded.
                           •                       -        •                       - AED 20,000
                              AED 10,000                    •  Failure to demonstrate substance:
                           •  Failure to demonstrate           1.
                              substance                           exchange with foreign competent authority of: (1)
                              Year 1: Penalty of AED 50k

                                                               2.
                                                                  Penalty of AED 400k; and trade / commercial license
                              commercial license could            could be suspended withdrawn or not renewal
                              be suspended withdrawn
                              or not renewal
          Mode of                                                              nistry of Finance

          and




              The Institute of Chartered Accountants of India (Dubai) Chapter NPIO           TAX JOURNAL 2020    77
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